Category: Podcasts

7 Apr, 2019

Episode 84 — A Review of MTS Telesystems FCPA Enforcement Action

In another blockbuster FCPA prosecution, the Justice Department and the SEC announced an $850 million settlement with Mobile Telesystems (“MTS”), Russia’s largest mobile carrier. At the same time, the Justice Department announced criminal indictments against an MTS executive and the notorious corrupt Uzbek official, Gulnara Karimova, on criminal charges. In this episode, Michael Volkov discusses the MTS Telesystems FCPA enforcement action.

Podcasts

31 Mar, 2019

Episode 83 — Managing Hotlines and Reporting Systems

Corporations have to invest in their Speak Up Culture. A critical component is a company’s hotline and incident reporting system. An effective hotline reporting channel(s) depends on responsive and timely investigations of potential wrongdoing. In this Episode, Michael Volkov discusses best practices for hotline and reporting systems.

Podcasts

24 Mar, 2019

Episode 82 — A Deep Dive into the Cognizant Technology FCPA Enforcement Action

In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million. At the same time, the Justice Department announced: (1) its’ declination under the FCPA Corporate Enforcement Policy; and (2) the indictment of Cognizant’s former President and General Counsel for criminal FCPA violations. In this Episode, Michael Volkov discusses the Cognizant FCPA...

Podcasts

17 Mar, 2019

Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned

OFAC is off to a fast start in 2019. It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.

Podcasts

10 Mar, 2019

Episode 80 — Best Practices for Investigation of Allegations of Sexual Misconduct in the #MeToo Era

The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment. Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal and code requirements. The #MeToo era has resulted in increased reporting of sexual misconduct allegations and requires enhanced monitoring of corporate...

Podcasts

24 Feb, 2019

Episode 78 — Ethical Cultures and Proactive Measures to Mitigate Organizational #MeToo Risks

The corporate world has been rocked by major governance failures surrounding #MeToo incidents and complaints. Recently, Google suffered global walkouts by employees who were upset by Google’s payment of lucrative severance packages to senior executives forced to resign because of sexual misconduct issues, and a culture of sexual misconduct that included 48 sexual misconduct incidents resulting in the departure/termination of employees. Companies have to address...

Podcasts

17 Feb, 2019

Episode 77 — Implementing an Effective Trade Compliance Program

Companies involved in export and import activities face a variety of risks from sanctions and export controls created by a complex maze of regulations and oversight from the Department of State, Department of Treasury and the Department of Commerce. With the increasing complexity of sanctions regimes, companies have to devote significant attention and resources to implement an effective trade compliance program. In this episode, Michael...

Podcasts

10 Feb, 2019

Episode 76 — Review of 2018 AML Enforcement and Compliance Trends

Global prosecutors and regulators continued to increase anti-money laundering enforcement and regulatory actions. Global and US regulators have increasingly focused on beneficial ownership and transparency requirements. In 2018, FinCEN’s Customer Due Diligence rule went into effect. US prosecutors also brought several significant AML criminal prosecutions against large banks; the SEC has increased AML enforcement as part of reviews of internal controls. Regulators brought enforcement actions...

Podcasts

3 Feb, 2019

Episode 75 — 2018 False Claims Act Review

The Justice Department reported its 2018 fraud statistics showing $2.8 billion in recoveries under the False Claims Act. While this number is staggering, fiscal year 2018 recoveries were down from than $500 million from fiscal year 2017. Nonetheless, companies in the healthcare, defense and financial industries continue to face significant False Claims Act risks. In this episode, Michael Volkov interviews Jessica Sanderson, Of Counsel, at...